ML20203K997

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Forwards Special Team Insp Rept 50-397/86-11 on 860616-27. Need for Increased Mgt Control Over safety-related Work Indicated.Enforcement Action Re Apparent Violations Will Be Subj of Separate Correspondence
ML20203K997
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 08/05/1986
From: Kirsch D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To: Sorensen E
WASHINGTON PUBLIC POWER SUPPLY SYSTEM
Shared Package
ML20203K999 List:
References
NUDOCS 8608220304
Download: ML20203K997 (6)


See also: IR 05000397/1986011

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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REGION V

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1450 MARIA LANE,SulTE 210

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WALNUT CREEK, CALIFORNIA 94596

AUG 051986

Docket No. 50-397

Washington Public Power Supply System

P. O. Box 968

3000 George Washington Way

Richland, Washington 99352

Attention:

Mr. G. C. Sorensen, Manager

Regulatory Programs

Centlenen:

Subject: NRC INSPECTION OF WASHINGTON NUCLEAR PROJECT NO. 2

This refers to the special team inspection conducted by Mr. R. T. Dodds and

other members of our staff on June 16-27, 1986, of activities authorized by

NRC License No. NPF-21, and the discussion of our findings held by Mr. Dodds

with Mr. J. W. Shannon and other members of your staff at the conclusion of

the inspection.

Areas examined during this inspection are described in the enclosed inspection

report. Within these areas, the inspection consisted of selective

examinations of procedures and representative records, interviews with

personnel and other observations by the inspectors.

Based on the results of this inspection, it appears that certain of your

activities were not conducted in full compliance with NRC requirements.

Enforcement action by the NRC relating to the apparent violations of regulatory

requirements discussed in the attached report will be the subject of separate

correspondence.

This inspection focused its effort upon your programs and controls associated

with the Residual Heat Removal System, Standby Service Water System and the

Emergency Diesel Generatorr and the implementation and adherence of those

programs and controls in the following areas: Plant Operations; Operator

Recovery Actions; Technical Specification Surveillance Program; Maintenance

Programs; Plant Modifications; Design Changes; Past Maintenance and Past

Modification Testing and Quality Assurance / Quality Control Program.

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G. C. Sorensen

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AUG 051986

Overall Conclusion

The apparent violations discussed in the enclosed report indicate that

management has not yet created the necessary atmosphere for performing

safety-related work or effectively communicated to the work force their

expectations. This conclusion is based on the number of violations involving:

(1) failure to perform work cctivities in accordance with approved instructions

and procedures; (2) repetitive nature of certain violations; and (3) a limited

quality control program that did not include prescribed criteria for

designating inspection requirements for certain types of maintenance

activities other than those prescribed by certain mandatory codes.

During the past year violations of similar nature have been brought to

the licensee's attention. The licensee's corrective actions for those past

items have apparently been ineffective to remedy the underlying problems

associated with ensuring that safety-related work activities are performed and

documented properly.

Areas Inspected and Results

Quality Assurance Surveillance and Quality Control

The onsite QA/QC group appears to have been given limited resources and the

scope of inspections are such that the effectiveness of the program is

questionable.

In several instances QA surveillance reports were inadequate

to show the efforts involved and contained errors and omissions. Actions to

correct identified deficiencies were on occasion untimely and OC inspection

requirements were generally determined solely by the QC group for corrective

maintenance. However, the maintenance foreman, among others, may call for a

particular inspection. Criteria had not been established to prescribe

inspection requirements for corrective maintenance other than those mandated

by applicable codes.

In addition, the value of the independence aspect of the QA/QC group appears

to be lessened by becoming overly sensitive to plant manaFement's priorities and

scheduling concerns as indicated by:

acceptance by QA of incomplete or inadequate commitments to correct

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deficiencies in a timely manner,

acceptance of delay in scheduled corrective action because of plant

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management priorities, and

excused missed commitments without obtaining documented alternates

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from plant management.

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G. C. Sorensen

AUG 051986

Corrective Maintenance

The licensee's maintenance program was examined by reviewing both the

corrective and preventive maintenance program. The effectiveness and control

of these maintenance programs were analyzed by reviewing completed maintenance

work requests (MWR).

The inspector determined that corrective action for a quality assurance

deficiency report on the maintenance work request (MWR) process was not

performed; and that problems stated by the deficiency still exist in the

documentation of the MWR's.

The inspector further identified an MWR which was

written for work on the motor operator of valve RHR-M0-6B and was amended,

after the MWR reviews were completed, to include work on the motor operator

for another valve, RHR-27B. Following this work, the MWR was not re-reviewed

by the maintenance group supervisor. The inspectors concluded that the

failure to initiate corrective action on the deficiency report and the failure

to implement the procedure appeared to be violations of regulatory

requirements.

Preventive Maintenance

The licensee's preventative maintenance program was examined by conducting an

intensive inspection of the Scheduled Maintenance System (SMS). Although the

inspection concentrated on the RHR system, the SSW system and diesel

generators preventative maintenance programs were also inspected.

The inspection included interviews with the individuals that implement the

program, a review of the procedures that are followed in running the SMS, a

comparison of how the program is carried out in three maintenance shops, a

review of maintenance records, and a walkdown of a day-to-day preventative

maintenance operation. Within this scope, two violatione were identified

pertaining to the lack of QC inspection and failure to follow procedures on

the installation of air start motors for the emergency diesel generators.

Maintenance Work Observation

The working conditions inside the cubical containing RHR-V-53B during the

overhaul of the valve lacked a proper environment for the control of safety

related work and personnel exposure and contamination control. Members of

management had visited the cubical and failed to question the existing

inadequate working conditions.

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AUG 051986

G. C. Sorensen

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Measuring and Test Equipment

The program for the control of Measuring and Test Equipment (M&TE) was

inspected to determine whether procedures were established and implemented to

assure that tools, gauges, instruments, and other measuring and testing

equipment used to calibrate and repair safety-related components and systems

were properly controlled, calibrated and adjusted to maintain precision and

accuracy within specified limits.

The control of Measuring and Test Equipment was not being implemented in

accordance with the approved program procedures. Specifically, items which

were supposed to be in the tool crib were missing, wire connector crimping

tools were not entered into the control list, and torque wrenches were out for

an extended period of time. These findings are similar to those identified

during the 1985 team inspections, for which enforcement action was taken.

It

appears that management's corrective actions were less than effective in

precluding recurrence of the situation. This is a repeat violation of

regulatory requirements in the area of M&TE.

Technical Specification Surveillance Program

The surveillance program was examined to assure that there existed a

responsible organization that administered the master schedule associated with

the surveillances required by the Technical Specifications.

Completed surveillances of the Residual Heat Removal, Standby Service Water

and Emergency Power systems were reviewed for completeness, timeliness and

test results. Generally, the program was found to be effective and well

implemented. There were, however, two areas that were not consistent with

program objectives; those being in the areas of performance trending and

station battery surveillance.

System Walkdown

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Walkdowns of the RHR system outside containment and an inspection inside

control room boards A, B and C, and control room panels 601, 602 and 603 were

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performed by the inspectors. Numerous examples of poor housekeeping and

presence of uncontrolled items inside electrical panels, which could cause

shorts of safety related circuits, were observed. Other items identified

included: missing and loose handwheels for instrument line and drain valves;

many overhead lights burned out; debris on floors and in RHR pump pit;

uncontrolled tonis; material blocking drain screens; etc. These items were

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brought to the licansee's attention. Accordingly, the licensee is requested

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to inspect inside til safety related electrical panels and remove all

uncontrolled items which could cause shorts.

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G. C. Sorensen

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AUG 051986

Operator Recovery Actions

The area of Operator Recovery Actions associated with the use and operation of

the Residual Heat Removal system (RHR) was examined. The level of operator

knowledge and understanding of the procedures used during emergencies that

involve use of the RHR system was found to be extensive. However, one item of

concern was identified related to the administrative control of approved

charts, and changes thereto, used in conjunction with the emergency

procedures.

Plant Modificatio-s

The design modification process at WNP-2 was reviewed to evaluate the adequacy

of the process with respect to the requirements of 10 CFR 50.59 and 10 CFR 50

Appendix B and to verify that sample design modification complied with the

written procedures that define the WNP-2 design modification program. The

design change program was found to provide adequate controls except in the

areas of post modification testing and independent reviews of MWR's that

implement quality modifications.

Emergency Procedures

The inspector reviewed the facility's emergency procedures in order to

ascertain whether their overall technical adequacy was consistent with desired

actions and modes of operation. The inspector also ascertained that emergency

procedures were in accordance with regulatory requirements. No areas of

concern were identified.

Plant Procedures

Administrative and system operating procedures pertaining to the RHR system

were reviewed against the FSAR and RHR flow diagrams. The procedures were

found to be adequate to control operations of the RHR system, but two valve

numbers needed to be removed from the Locked Valve Checklist, and nine valves

should be added. The licensee has agreed to'make these changes.

In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure

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will be placed in the NRC Public Document Room.

Should you have any questions concerning this inspection, we will be glad to

discuss them with you,

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Dennis F. K sch, Director

Division of Reactor Safety and Projects

Enclosure:

1.

Inspection Report No. 50-397/86-11

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cc w/ enclosures:

C. M. Powers, WPPSS

AUG 051986

P. L. Powell, WPPSS

R. B. Glasscock, WPPSS

J. D. Martin, WPPSS

G. E. Doupe, Esq., WPPSS

W. G. Conn, Burns & Roe, Inc.

State of WA

N. S. Reynolds, Esq., BLCP&R

C. J. Heltemes, AEOD

J. G. Partlow, IE

W. T. Russell, NRR

bec w/ enclosures:

Resident Inspector

Project Inspector

G. Cook

B. Faulkenberry

J. Martin

RSB/ Document Control Desk (RIDS)

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